HomeCost RecoveryM12619Evidence
Topic/Matter Intersection

Topic:"Cost Recovery" in M12619

Matter: Nova Scotia Power Inc. - 2026 Annual Capital Expenditure (ACE) Plan - $284 million
116 passages 25 documents

Cost Recovery across all matters →

N-1Application - Redacted 24 passages
Section 349
Project 4 24 20 18 17 % Defined/Complete 100% 100% 80% 72% 68% Percentage towards Class Estimate Comments: This project is being filed as a Class 3 estimate. The defined deliverables for this project indicate that 80% of Class 3 deliverabl...

AI summary This document outlines a Class 3 estimate for a project, indicating that 80% of deliverables are completed. A 15% contingency is included to cover execution risks, market changes, and feedback from governing authorities such as the Department of Fisheries and Transport Canada.

Section 621
r be liable for more than the price charged for such material as may prove defective, and no payments shall be withheld by Buyer pending adjustment of liability or amount of cost of alleged errors. For specific questions Date: about line D...

AI summary The text outlines terms and conditions related to liability and payment adjustments for defective materials, specifying that buyers should not withhold payments pending resolution of liability or cost adjustments. It also includes a quotation and contact information for Gavin McInnis from Nova Scotia Power - Tuft's Cove.

Section 676
l Plan & Drawings Not Applicable (NA) NR Foundation / Structure (Tower) Discipline Drawings Preliminary (P) NR S/P P Tower / Structure Location / Spotting Complete (C) NR S/P P C C Instrument Datasheets Complete (C) NR NR/S P P/C C Electri...

AI summary The project is being filed as a Class 3 estimate with 91% of deliverables completed. A 15% contingency was selected to account for unforeseen material and contract cost increases, schedule setbacks, and execution complications.

Section 739
100% 100% 59% 44% 44% towards Class Estimate Comments: This project is being filed as a Class 3 estimate. The defined deliverables for this project indicate that 59% of Class 3 deliverables are completed. A contingency value of 20% was sel...

AI summary The document discusses the filing of a Class 3 estimate for a project, with 59% of deliverables completed. A 20% contingency was included to manage risks such as contractor availability, delays in long-lead material delivery, and material cost increases due to tariff threats.

Section 745
support is limited as vendor is no longer in business. Replacement is the most reliable and cost-effective solution to ensure long-term performance and environmental protection. Contingency Statement Contingency for this project has been d...

AI summary The document discusses the replacement of a transformer due to the vendor no longer being in business, emphasizing that replacement is the most reliable and cost-effective solution for long-term performance and environmental protection. A contingency of 15 percent has been applied to the project based on internal expert judgment and previous experience.

Section 765
Not Applicable (NA) NR Foundation / Structure (Tower) Discipline Drawings Not Applicable (NA) NR Tower / Structure Location / Spotting Not Applicable (NA) NR Instrument Datasheets Complete (C) NR NR/S P P/C C Electrical Discipline Drawings...

AI summary The project is being submitted as a Class 3 estimate with 97% of deliverables completed. A 10% contingency was selected to account for risks such as overtime work, material costs, and contract cost increases.

Section 807
NR Tower/Structure Location/Spotting Not Applicable (NA) NR Instrument Datasheets Not Applicable (NA) NR NR/S Electrical Discipline Drawings Complete (C) NR NR S/P P/C C Instrumentation/Control System Discipline Drawings Not Applicable (NA...

AI summary This project is being filed as a Class 3 estimate with 85% of deliverables completed. A 10% contingency was selected to cover risks like equipment replacement, transformer load balancing, and additional tree trimming along service lines.

Section 839
C C C Data Architecture Complete (C) P P C C C Security Assessment Complete (C) NR P C C C Privacy Impact Assessment Not Applicable (NA) NR Information Systems / Telecommunication Drawings Preliminary (P) NR P Total # Deliverables for this...

AI summary The project is submitted as a Class 3 estimate, with 79% of deliverables completed. A 10% contingency is included to address risks such as foreign currency fluctuations, additional tariffs, resource rate increases, and potential overtime work.

Section 945
SEB on December 1, 2025 52314 1C-GT1/UT1 Replacement 11/30/2020 2,032,393 1,678,006 FIN CWO submitted to NSEB on December 1, 2025 This project is now complete; however, the final cost application is being held until the functionality C0042...

AI summary The text provides information on several completed projects with pending final cost applications, including IT security upgrades, wood pole retreatment, and smart grid initiatives. These projects are being processed by the Nova Scotia Energy Board (NSEB) under various proceedings, with final costs contingent on investigations and asset disposition processes.

Section 950
REDACTED (CONFIDENTIAL INFORMATION REMOVED) 2026 ACE Plan Appendix D Page 8 of 179 New Updates – FIN • FINs often take more time to process than other capital applications, due to required final costing activities. • In particular, undersp...

AI summary The 2026 ACE Plan Appendix D discusses challenges in processing FINs, particularly underspent ones, due to delays in final costing and unused contingency. It recommends adjusting the underspend threshold and extending the timeline for filing to improve regulatory efficiency.

Section 958
1.0 Defini ons ......................................................................................................................... 4 2.0 Introduc on .......................................................................................

AI summary The document outlines the capital planning process for NS Power, including budgeting, execution, ranking, and economic analysis. It also discusses financial criteria, parameters, and the types of capital applications submitted for NSEB approval, along with the requirements for such approvals.

Section 973
s of the capital approval process. This begins during the development and submi al of the ACE Plan and con nues un l the project is complete and receives final cost approval. NS Power is commi ed to: • Delivering effec ve and efficient servic...

AI summary The Capital Expenditure Justification Criteria (CEJC) ensures NS Power uses consistent economic, financial, and technical standards to justify capital spending, aiming to maximize customer benefits and minimize rate impacts. The process begins with the submission of the ACE Plan and continues until final cost approval.

Section 990
ty on what is included in the costs comprising each alterna ve. Addi onal clarifying notes, if necessary, can be wri en onto the “Notes/Comments” sec on on the first page/tab of the EAM. Administra ve Overhead (AO) - Project capital cost a...

AI summary The document outlines the inclusion of administrative overhead (AO) in the revenue requirement analysis for capital projects and discusses the potential impact of removing the AO credit on economically justified projects. It emphasizes the need for careful evaluation of AO credits to ensure appropriate project recommendations.

Section 996
eturn mul plied by the por on of equity to total capital of the incremental rate base.¶ • Addi onal fixed cost recovery received from customer growth achieved through capital investment to serve these customers.¶ Deprecia on expense and ad...

AI summary The text discusses the calculation of revenue requirements in the context of the 2026 ACE Plan, highlighting depreciation expense and additional fixed cost recoveries. It notes that the method used does not fully account for certain factors, as indicated by the ellipsis.

Section 1008
2026 ACE Plan Appendix D Page 42 of 179 Nova ScoƟa Power Inc. Capital Planning & Capital Expenditure JusƟficaƟon Criteria Summary Document Capital Projects in ATO PosiƟon If a previously approved capital project exceeds the allowable varia...

AI summary Nova Scotia Power outlines criteria for capital projects exceeding approved budgets, requiring ATO applications for variances over 5% or $250,000. Unapproved spending above $1M risks exclusion from rate base until Board approval. Projects not filed within six months face quarterly rate base reductions.

Section 1045
tal Item ATO.................................................................................. 49 12.2 Individual Capital Item Scope Change .................................................................. 49 12.3 Rou ne Capital ATO ........

AI summary The text outlines a document structure covering capital expenditure management, cost application requirements, asset remittance, routine expenditures, and justification criteria. It emphasizes regulatory processes for financial compliance, capital item scope changes, and confidentiality protocols within a regulatory proceeding context.

Section 1085
imal effect on rate base or associated revenue requirement and therefore it is examine further those projects where elimina on of the AO credit from the revenue excluded from the calcula on.¶ requirement analysis could affect the recommended...

AI summary The document discusses the impact of removing the Administrative Overhead (AO) credit from revenue requirement analysis on economically justified projects, emphasizing NS Power's need to assess effects on rate base, revenue requirement, and project recommendations. It also references the Production Costing Model for fleet dispatch forecasts.

Section 1094
Not proceeding with such a project, and therefore foregoing increased heat rate efficiency, does not impact the safe and reliable opera on of NS Power’s system. Generally with discre onary investments, NS Power seeks projects that provide re...

AI summary NS Power outlines its approach to capital expenditures, emphasizing discretionary investments that minimize revenue requirements and align with financial or strategic objectives. Essential capital projects are prioritized, while discretionary projects require approval based on economic evaluations. The document is part of the 2026 ACE Plan Appendix D.

Section 1110
wn from stores or spares do create payments to an outside en ty when they are replaced and must be included in the es mate. 9.1.3.3 Receipts from the sale of by-products A by-product is any physical result of an alterna ve which is not a p...

AI summary The text discusses financial considerations for capital investments, including payments from replacing assets, credits from by-product sales, and methods for comparing projects with unequal lifespans (e.g., chain replacements or terminal values). By-product revenues reduce operating & maintenance costs in revenue requirement calculations.

Section 1123
meframe un l these costs are submi ed for approval to the NSEB. Capital Projects in ATO PosiƟon Month DD, 2025 Page 47 of 113 Date: December 12, 2025 Page 566 of 782 REDACTED REDACTED (CONFIDENTIAL INFORMATION REMOVED) 2026 ACE Plan Append...

AI summary Nova Scotia Power Inc. outlines capital expenditure justification criteria, requiring approval from the Nova Scotia Energy Board (NSEB) for projects exceeding approved amounts. Unapproved capital spending above $1 million may be excluded from rate base until formal approval is obtained.

Section 1129
lec ng the Final Cost of the project; • Line by line project account variance explana ons will be provided for those accounts with material variances; and • Project scope variances. All projects should be final costed within twelve months...

AI summary The document outlines requirements for final cost submissions within 12 months of a project's in-service date, exceptions for delays, and rate base rules for projects in ATO positions. It also discusses retirement of capital assets due to normal wear and tear or inadequacy.

Section 1229
2026 ACE Plan Appendix E Page 4 of 17 Mersey Hydro Update Non-Confidential 1 The sections below provide NS Power’s response, including: 2 3 • An update on the incremental sustaining investments that have been incorporated into the 4 Hydro...

AI summary NS Power outlines updates on Mersey Hydro redevelopment, including sustaining investments in the Hydro Interval Plan (HIP), stakeholder engagement with First Nations and government, an NPV analysis comparing redevelopment options, and cost estimates for preliminary engineering and procurement for 2028. The analysis includes assumptions and engagement details.

Section 1267
Scenario TOTAL or NPV 2039 2040 2041 2042 2043 2044 2045 2046 2047 2048 2049 2050 2051 Partial Decommissioning Total Capital Investment $ 624,440,000 $ 54,850,000 $ 48,140,000 $ 54,850,000 $ 48,140,000 $ 28,770,000 $ 15,550,000 NPV (CAPEX)...

AI summary The text presents financial scenarios for energy infrastructure projects in Nova Scotia, including partial and full decommissioning, redevelopment, and sustaining capital expenditures. It details total capital investments and net present values (NPV) for each scenario across multiple years, highlighting the financial implications of different investment strategies.

Section 1522
DM documentation that is intended to inform project planning and execution. The following lists the relevant PDM documentation, and what should be reviewed: Contingency Assessment (if applicable) Review this document to ensure it’s aligned...

AI summary The text outlines documentation to be reviewed for project planning and execution, including Contingency Assessment, Estimate Maturity Matrix, Economic Analysis Model, Risk Register, and Post Project Review. These documents ensure alignment with guidelines, proper risk management, and accurate cost estimation.

N-3NSPI (CA) RIR 1 to 32 - Redacted 2 passages
2026 Annual Capital Expenditure (ACE) Plan (NSEB M12619) NSPI Responses to Consumer Advocate Information Requests p. p. 26
2026 Annual Capital Expenditure (ACE) Plan (NSEB M12619) NSPI Responses to Consumer Advocate Information Requests 2 3 With respect to Appendix I, CIs for transmission replacement and upgrade projects 4 C0080110 and C0080109, and 2024 ACE P...

AI summary The document pertains to the 2026 Annual Capital Expenditure (ACE) Plan (NSEB M12619) and includes NSPI's responses to Consumer Advocate Information Requests. It addresses questions regarding risk registers, cost accountability mechanisms, and project documentation for transmission replacement and upgrade projects.

NON-CONFIDENTIAL p. p. 69
NON-CONFIDENTIAL 1 (e) Yes, vegetation management is covered by the Project Delivery Model. Cost minimization 2 actions in the past have included working with the Provincial Department of Public Works 3 to combine efforts in areas where ro...

AI summary The text discusses cost minimization strategies in vegetation management, including collaboration with provincial and private entities, reducing right-of-way widening, and sharing resources. It also mentions the intent to increase vegetation management work using allocated funding for reliability improvements.

N-4NSPI (DOE) RIR 1 to 7 1 passage
2026 ACE NSDoE IR-001 Attachment 1 p. p. 7
2026 ACE NSDoE IR-001 Attachment 1 Status CI Number Title First Approval Year Original Approved Project Cost 2026 ACE Project Total Variance ($) Variance % 18 Canada and North America? If so, please provide. 19 20 (e) Explain whether lower...

AI summary The document discusses distribution capital planning linked to customer additions and historical data, as well as the use of risk-based investment for reliability. It also requests information on cost-containment measures and connection standards to mitigate rate base impacts.

N-6NSPI (NSEB) RIR 1 to 202 - Redacted 3 passages
NON-CONFIDENTIAL p. p. 44
NON-CONFIDENTIAL 1 (i) Given the amount of subsequent spending on this project, what is the revised 2 Final Date for this project? 3 4 (ii) Please discuss the delay in this project that was started 2024/08. 5 6 Response IR-16: 7 8 Yes. Pro...

AI summary The response discusses the revised final date for a project and the reasons for delays, including budget variances and project progress updates. Specific projects like the Tusket Falls Main Dam and HYD WRC Tailrace Rock Bolting Phase 2 are mentioned with their current status and estimated costs.

NON-CONFIDENTIAL p. p. 72
NON-CONFIDENTIAL Capital Contributions (1,242) Overall Total 5,360 Number of D061 units 6562 D062 Unit Rate per Customer 2025 Actuals ($) Regular Labour and Term Labour 4,384 Overtime Labour 1,350 Materials 15,352 Contracts/Consulting 4,33...

AI summary The document presents detailed financial data related to capital contributions, cost breakdowns, and funding sources for various projects (D004, D061, D062). It includes tables showing labour, materials, overheads, and recovery costs, as well as the proportion of capital costs funded by NS Power and customer contributions.

Summary: p. p. 105
Summary:

AI summary The document provides a summary of the proceeding, outlining key issues and stakeholders involved. It highlights the need for regulatory oversight and compliance with energy policies, including the discussion of cost recovery mechanisms and program evaluations.

N-9Evidence of John D. Wilson - CA 11 passages
1 2 3 2. Direct NS Power to provide a report on whether the Maximo/Salesforce capabilities could be extended to improve operational efficiency and cost minimizatio p. p. 3
1 2 3 2. Direct NS Power to provide a report on whether the Maximo/Salesforce capabilities could be extended to improve operational efficiency and cost minimization in areas where it is not currently scoped for use. (Section III.A) 4 5 3....

AI summary The document outlines various directives for NS Power, including improving operational efficiency through software capabilities, revising work orders, monitoring external cost factors, managing contingency amounts, and revising the CEJC to align with the Board's requirements. It also addresses reliability metrics and spare equipment inventory.

A. Enhancing cost minimization in capital routines p. p. 5
A. Enhancing cost minimization in capital routines

AI summary The section discusses strategies for enhancing cost minimization in capital routines, focusing on optimizing processes and reducing expenses associated with capital projects.

Q: Is there any further evidence that NS Power lacks internal controls to ensure effective planning of resources to minimize costs? p. pp. 5-7
Q: Is there any further evidence that NS Power lacks internal controls to ensure effective planning of resources to minimize costs? A: Yes, NS Power does not utilize a Basis of Schedule practice, or its equivalent, for its capital routine...

AI summary NS Power does not use a Basis of Schedule practice for its capital routine projects, which may indicate a lack of internal controls for resource planning. However, for some routines, this is reasonable due to their reactive nature. For other routines, an equivalent practice could help avoid delays and costs. NS Power has reported efficiency improvements from implementing new software, resulting in $2.7 million in savings.

Q: If your deduction is correct, is a policy to not utilize a risk matrix or detailed schedule for projects with a 15% contingency reasonable? p. p. 11
Q: If your deduction is correct, is a policy to not utilize a risk matrix or detailed schedule for projects with a 15% contingency reasonable? A: No. If these projects are so well understood and so consistent, then a much smaller contingen...

AI summary The response argues that not using a risk matrix or detailed schedule for projects with a 15% contingency is unreasonable, especially if projects frequently exceed budgets. It emphasizes the importance of proactive risk management to minimize costs for capital projects.

Q: Could a smaller contingency budget increase the number of ATO proceedings? p. pp. 11-13
Q: Could a smaller contingency budget increase the number of ATO proceedings? A: Yes, a possible consequence of the Board adopting my recommendation is that there could be slightly more ATO proceedings. From a cost minimization perspective...

AI summary A smaller contingency budget may lead to more ATO proceedings, as they can identify risks that lead to overspending in capital projects. Examples include the L6549 transmission line project and the 76V-T1 Transformer Replacement, where unexpected costs led to increased ATO budgets. Improved planning and risk management could help mitigate these issues.

Q: Do you have any other comments on NS Power's vegetation management program? p. pp. 15-16
Q: Do you have any other comments on NS Power's vegetation management program? A: Yes. In a response to an information request, NS Power seems to suggest that it was able to "exceed the planned kms" of trimming and removal of trees through...

AI summary The response discusses NS Power's vegetation management program, noting that it shifted resources from capital projects to operating expenses for tree trimming. The responder acknowledges this as an efficient reallocation but hopes the good practices and cost minimization are ongoing.

Q: What is NS Power's view of the risk of adding detail to the scope, consistent with some other definitions of scope? p. p. 19
Q: What is NS Power's view of the risk of adding detail to the scope, consistent with some other definitions of scope? A: NS Power states that if "scope change" included changes in deliverables, boundaries, and/or detailed tasks, roughly 7...

AI summary NS Power believes that adding detail to the scope of projects would lead to a significant regulatory burden, as approximately 70-80 out of 200 projects over the past five years would have required a scope change, affecting NS Power, the NSEB, and stakeholders, with costs passed on to customers.

Q: Is there a clearly best alternative? p. p. 24
Q: Is there a clearly best alternative? A: No. If the Mersey Hydro system were a greenfield power project, it would not be seriously considered: In NPV terms, the cost of $560 million far exceeds the benefit of $475 million. But of course,...

AI summary The Mersey Hydro system is not a greenfield project, and NS Power must manage it responsibly, leading to costs that customers must bear. The NPV analysis shows a cost of $560 million exceeding the benefit of $475 million, indicating no clearly best alternative.

Q: Is the NPV analysis reasonably complete? p. pp. 24-25
Q: Is the NPV analysis reasonably complete? A: No. The Mersey Redevelopment Project was first identified as a subsequent submittal project in 2017, and retained in each ACE Plan on the same basis until it was moved to deferred status in th...

AI summary The NPV analysis is deemed incomplete due to high uncertainty in the decommissioning cost estimate for the Mersey Redevelopment Project, with NS Power not providing a direct comparison to redevelopment cost estimates. The project has been in study for nearly a decade, and the current estimate is based on high-level metrics without full scope consideration.

SUMMARY OF PROFESSIONAL EXPERIENCE p. p. 28
SUMMARY OF PROFESSIONAL EXPERIENCE - 2023– Present Vice President, Grid Strategies, LLC . Provides research, technical assistance, and expert testimony on electric- and gas-utility planning, economics, and regulation. Reviews electric util...

AI summary The individual has extensive experience in energy regulation, utility planning, and environmental policy, spanning over two decades in roles involving regulatory policy, expert testimony, and program evaluation. Their work includes advising on electrification, energy efficiency, and renewable resource performance, as well as participation in air quality and legislative advocacy.

EXPERT TESTIMONY p. p. 28
EXPERT TESTIMONY - 2008 South Carolina PSC Docket No. 2007-358-E, surrebuttal testimony on behalf of Environmental Defense, the South Carolina Coastal Conservation League, Southern Alliance for Clean Energy and the Southern Environmental L...

AI summary Expert testimony from various regulatory proceedings in multiple U.S. states discusses the cost recovery mechanism for energy efficiency, including shareholder incentives and lost revenue adjustment mechanisms, as well as the adequacy of energy efficiency considerations in integrated resource plans.

N-12Rebuttal Evidence - NS Power 1 passage
2.17 Mersey Hydro Update The Wilson Evidence expressed concern that NS Power "does not have a strong plan for protecting customers from excessive costs when dealing with the potential redevelopment or decommissioning of the Mersey Hydro project". Currently, NS Power is continuing to invest significant sums to "ensure the continued safe operation" of Mersey facilities while it has deferred a full application for either redevelopment or decommissioning. While I do not dispute what appear to be necessary projects given the circumstances, it is unfortunate that this project was not more definitively defined years ago. At the same time, the Wilson Evidence does not dispute the prudence of the projects currently being undertaken to maintain the safe operation of the Mersey Hydro System (MHS), acknowledging that such work appears necessary given the circumstances. The concern expressed relates primarily to the fact that the future of the MHS was not "more definitively defined years ago." Notably, the Wilson Evidence does not make a specific recommendation to the Board regarding the Mersey Hydro project. It is important to distinguish the sustaining capital currently being undertaken from the uncertainty surrounding the long-term future of the MHS. NS Power's current sustaining capital investments are not driven by, nor contingent upon, whether the facilities are ultimately redeveloped or decommissioned. To be clear, continuing to invest in sustaining capital investment to support the continued operation of MHS assets in their current state, while deferring long-term investment, is the lowest-cost approach and provides the best value for customers at this time. Further, these expenditures are required to maintain the facilities in a safe and operable condition and would be incurred regardless of the eventual path forward. In other words, the Company would undertake its sustaining capital work in the same manner, regardless of whether redevelopment or decommissioning had already been selected. p. p. 15
6 Page 16 of 19 Consistent with prior Board direction, NS Power has filed a comparative Net Present Value (NPV) analysis evaluating redevelopment, partial decommissioning, and full decommissioning

AI summary The Wilson Evidence expresses concern that NS Power lacks a strong plan to protect customers from excessive costs related to the potential redevelopment or decommissioning of the Mersey Hydro project. NS Power is currently investing in sustaining capital to ensure safe operation while deferring long-term decisions. These investments are not contingent on the future of the Mersey Hydro System and are necessary to maintain safe operations regardless of eventual decisions.

N-13Letter of Comment 1 passage
Mr. Chair and Board Members:
explain why ratepayers are expected to continue paying for the growth of an old asset fleet they are moving away from, while simultaneously paying for the transition to new renewable energy services? - 6. How does the utility justify using...

AI summary The text raises concerns about ratepayers being expected to fund the decommissioning of outdated assets while transitioning to renewable energy, and questions the utility's use of mechanisms like the fam-fuel account and dda to continue extracting value from depreciating assets. It also inquires about the return on equity and penalties NS Power is willing to pay for failing to deliver reliable power and invest in renewables.

N-16Opening Statement - DOE 3 passages
The Reliability Gap
The Reliability Gap - NSPI submits that a significant portion of this spending falls under the rubric of 'reliability.' - Yet the record shows a disconnect between spending and performance, as despite years - of aggressive reliability inve...

AI summary NSPI argues that a significant portion of its spending falls under 'reliability,' but the Department points out a disconnect between spending and performance, as reliability targets have not been met since 2016. NSPI's reliability plan lacks specific performance targets, and the Department criticizes the lack of measurable improvements and poor asset management practices.

Project Management and Cost Overruns
Project Management and Cost Overruns - The ACE Plan yet again reveals a systemic lack of accountability regarding project - management. NSPI's attempt to limit the definition of a "Scope Change" appears designed - to reduce or avoid oversi...

AI summary The ACE Plan highlights a systemic lack of accountability in project management by NSPI, with efforts to limit the definition of 'Scope Change' to avoid oversight. Cost overruns have occurred, with increased spending on projects like Hydro plants and transportation vehicles raising concerns about ratepayer burden and reliability of original estimates.

Call for Regulatory Rigour and Accountability
Call for Regulatory Rigour and Accountability - The Department requests that the Board scrutinize the 2026 ACE Plan; seeing it not as a - collection of routine repairs, but rather recognizing it as potentially yet another round in - the sy...

AI summary The Department of Energy requests the Board to rigorously scrutinize the 2026 ACE Plan, questioning its potential to inflate asset purchases and urging the cancellation or deferral of expenditures without proper justification. It also calls for disallowing ratepayer funding for projects that would represent a 'double recovery' for system failures already covered by the utility.

N-22Responses to Undertakings 1-22 1 passage
- 7 in 2024, and by the applicable 2024 blended IBEW hourly rate, including fringe benefits. p. p. 0
- 7 in 2024, and by the applicable 2024 blended IBEW hourly rate, including fringe benefits. 1 Undertaking U-2: 2 3 Per Exhibit N-9, pdf pg. 11 (Wilson Evidence), to advise whether the data would be useful 4 for improved cost allocation be...

AI summary The document discusses the utility's response to a request for data to improve cost allocation and rate design. NS Power concludes that the proposed granular customer-type data would not significantly improve cost allocation or rate design outcomes and does not recommend implementing the proposed data collection.

103410Decision 8 passages
2.2.2 C0021608 – TUC Shoreline Sheet Pile Refurbishment p. p. 7
may have changed the scoring spread. The Board also expressed similar spread concerns related to scoring the options' costs, as it was not based on pro-rating an option cost to the lowest option cost. • The use of additional study data to...

AI summary The document discusses concerns raised by the Nova Scotia Energy Board regarding the cost estimates of the rock revetment option for the TUC Shoreline Sheet Pile Refurbishment project. Additional study data significantly increased the cost of this option, leading the Board to question whether it remains the most cost-effective solution without re-evaluating the other options.

2.3.1.1 Findings p. pp. 18-20
2.3.1.1 Findings [44] The Board accepts that an increase in expenditure does not, in itself, mean that an activity ceases to qualify as routine. Required expenditures may reasonably vary with asset conditions, customer growth, system requi...

AI summary The Board acknowledges that increased expenditure does not automatically disqualify an activity as routine but is concerned that temporary cost increases may become embedded in historical data, influencing future forecasts. NS Power is urged to clearly distinguish between structural and temporary cost drivers in future ACE Plans.

2.3.6 Spare Inventory Pooling p. pp. 28-29
2.3.6 Spare Inventory Pooling [74] Mr. Wilson examined whether spare inventory pooling could provide a more cost-effective alternative to NS Power independently maintaining certain high-value, longlead-time spare equipment. He recommended...

AI summary The document discusses spare inventory pooling as a potential cost-effective alternative to NS Power maintaining high-value, long-lead-time spare equipment. Mr. Wilson recommended obtaining detailed information on NS Power's existing inventory and suggested focusing on equipment with a minimum two-year holding period and a materiality threshold. NS Power, however, stated that previous investigations found existing arrangements less cost-effective and operationally reliable than its current strategy, citing concerns like availability, compatibility, and transportation.

2.4.2 Directives p. p. 33
2.4.2 Directives [88] The Board finds that the sustained growth and evolving composition of the Routine Program require requires enhanced prospective transparency. The additional information is intended to preserve the regulatory efficienc...

AI summary The Board requires NS Power to enhance transparency in the Routine Program by providing detailed cost and performance data, including five-year comparisons, cost breakdowns, and explanations for year-over-year changes. This is intended to ensure regulatory efficiency and proper cost justification.

3.2.1 Findings p. p. 42
project costs and/or operational risks would not arise with a delay in work. In these cases, a Scope Change application would be prospective, providing the Board with regulatory oversight in advance. [113] NS Power also stated that it ende...

AI summary NS Power emphasizes the importance of timely filing of ATO applications to avoid cost recovery delays. The Board acknowledges this but notes that there may be situations where a Scope Change application is needed before the ATO threshold is exceeded, allowing for regulatory oversight in advance.

6.2 Regulatory Compact p. pp. 67-68
6.2 Regulatory Compact [179] Any analysis of what affordability means in the public utility context starts with the regulatory compact enshrined in the Public Utilities Act . In essence, in return for fulfilling an obligation to provide re...

AI summary The regulatory compact under the Public Utilities Act establishes that public utilities must provide safe, reliable service and can recover prudently incurred costs and a reasonable return on equity. Affordability in this context relates to selecting the least costly option to meet service requirements, as outlined in cost of service and rate of return frameworks.

8.3 Considerations for Subsequent Submittal Items p. pp. 84-85
8.3 Considerations for Subsequent Submittal Items [212] There was discussion about IT or cybersecurity-related projects listed as subsequent submittal items in the 2026 ACE Plan. Two projects, in particular, raised several concerns. The Id...

AI summary The document discusses concerns raised about the increasing costs of IT and cybersecurity-related projects, specifically the Identity and Access Management and Customer Information System (CIS) Replacement projects. The Industrial Group recommends that future submittals include detailed cost explanations related to the 2025 cyber incident. NS Power argues that current processes already provide necessary information, but the Board agrees that specific references to the impact of the cyber incident on cost variances should be included in future submissions.

11.0 CONCLUSION p. p. 96
ant cost categories. For Routines using internal labour the information should also include a breakdown of labour costs (regular and overtime labour, budgeted costs and hours, actual costs and hours). - 3. NS Power must provide sufficient...

AI summary The document outlines requirements for NS Power to provide detailed cost breakdowns and explanations for changes in routine expenditures, including labour, materials, and contractor costs. It also mandates the use of existing systems for productivity monitoring and the inclusion of Routine Expenditure provisions in the 2028 ACE Plan review.

103411Board Order 1 passage
ORDER
ant cost categories. For Routines using internal labour the information should also include a breakdown of labour costs (regular and overtime labour, budgeted costs and hours, actual costs and hours). - 3. NS Power must provide sufficient...

AI summary The document outlines requirements for NS Power to provide detailed cost breakdowns and explanations for changes in routine expenditures, including labor, materials, and contractor costs. It also mandates monitoring of planned versus reactive replacement activities and the inclusion of Routine Expenditure provisions in the 2028 ACE Plan.

100690NSEB (NSPI) IR 1 to 202 - PDF 4 passages
Request IR-94:
Request IR-94: - If the inspection reveals that that some parts and/or components do not need to be replaced, can - already purchased replacement parts be returned for no additional cost to the project? Please - explain. - a) If not, why n...

AI summary The text raises a question about whether replacement parts already purchased can be returned without additional cost if an inspection reveals they are not needed, and requests an explanation if they cannot be returned.

a) If not confirmed, please explain.
a) If not confirmed, please explain. G07: C0068888 TUC3 Continuous Ash Hauling System Request IR-96: The application considers that this investment will reduce operational costs. - a) What are the annual forecasted costs of NS Power to per...

AI summary The document contains multiple requests for information regarding the Continuous Ash Hauling System and Engine Refurbishment projects. It asks about costs, maintenance schedules, TCO analysis, and the reasons for selecting specific systems and contractors. It also inquires about the operating history of a turbine unit and the OEM's recommendations for refurbishment.

Request IR-138:
Request IR-138: - The application notes that Phase 11 will be influenced by vegetation condition data derived from Satellite Imagery and artificial intelligence. This data will allow NS Power to be better informed on the updated vegetative...

AI summary The application for Phase 11 highlights the use of satellite imagery and artificial intelligence to improve vegetation condition data and prioritize feeder work. A request is made for a cost-benefit analysis to demonstrate that these technologies will be cost-effective.

Request IR-189:
Request IR-189: In reference to Demonstrated Reliability Impact/Benefit on page 719, NS Power states "… it is important to recognize that the full impact of the program will take time to materialize. Meaningful trends and improvements in S...

AI summary NS Power asserts that the full impact of a $1.3B investment in reliability improvements will take time to materialize, with meaningful trends in SAIDI only being accurately assessed over the full duration of the program. The question raised is about ratepayer recourse if the investment fails to deliver expected improvements.

100691NSEB (NSPI) IR 1 to 202 - Word 4 passages
Section 31
severe, and the remainder of the cells below the midtide zone where capacity is compromised. Without intervention, the continued deterioration poses serious risks to structural stability and safety.” 1. What are the net present value and t...

AI summary The text discusses concerns about the structural integrity of corroded steel sheet pile structures and requests for cost-benefit analyses, design drawings, RFP status, and permitting progress for a project. It highlights the need for economic assessments and regulatory engagement.

Section 39
r no additional cost to the project? Please explain. 1. If not, why not? In reference to Attachments 1 and 2, please confirm the noted pricing was obtained through a competitive procurement process. 1. If not confirmed, please explain. G07...

AI summary The text includes a series of questions related to the cost and procurement process of a fly ash hauling system and engine refurbishment project. It requests confirmation of competitive procurement, cost details, and evaluation of alternative systems. The questions also cover maintenance, cost savings, and Total Cost of Ownership (TCO) analysis.

Section 41
ned to be more cost effective to refurbish the existing engine rather than purchasing a previously owned engine.” Please provide the analysis/data to support that refurbishment is more cost effective. Please describe any work NS Power has...

AI summary The text contains a series of questions directed at Nova Scotia Power (NS Power) regarding the cost-effectiveness of refurbishing an existing engine, sourcing materials, capital and operational costs of the CT-BGT2 unit, and the basis for project estimates related to transmission upgrades.

Section 71
e describe the planned maintenance schedule for right-of-way widening. 2. Please describe how the planned maintenance schedule accounts for local vegetation, weather and other geographical attributes. In reference to Demonstrated Reliabili...

AI summary The text includes questions about NS Power's maintenance schedules, the impact of a $1.3B investment on reliability metrics like SAIDI, the use of the 2025 vegetation management budget, and the selection and remote operation of reclosers and trip savers. It also asks for a breakdown of 2025 investments.

100700IG (NSPI) IR 1 to 25 - Word 1 passage
Section 7
variance; and 2. the qualitative factors influencing project‑level reallocation decisions. Reference: N-1, 2026 ACE Plan, page 17, Figure 4: Breakdown of Capital Forecast by Investment Type. 1. Please explain how NSPI tracks and recovers c...

AI summary The document outlines questions regarding NSPI's tracking and recovery of Right-of-Way costs, including capital vs O&M treatment, and increasing expenditures for ROW widening. It also references the Board's directive for NS Power to seek approval for future capital expenditures exceeding $1 million, with an example project included for approval.

100701DOE (NSPI) Ir 1 to 7 - PDF 4 passages
Request IR-1:
Request IR-1: For each of the projects listed below: - C0014218 HYD WRC LEM Balance of Plant - 29807 HYD Tusket Falls Main Dam - C0021140 New 138KV-25KV Substation Stellarton - C0045132 Eastern Clean Energy Initiative (ECEI) Energy Storage...

AI summary Request IR-1 asks for detailed cost and impact information on various energy projects, including initial approval costs, changes in cost, rate impacts, and mitigation actions taken by NS Power. The request focuses on projects with a cost change of 30% or more from their original approval.

Reference: Exhibit N-1: Application - Section 8.0 Distribution
Reference: Exhibit N-1: Application - Section 8.0 Distribution a) Please explain how Distribution capital planning is explicitly linked to historical and forecast customer additions, specifically addressing any deviations from the historic...

AI summary The document contains a series of questions aimed at understanding NS Power's distribution capital planning, spending, cost justification, benchmarking, connection standards, and cost-containment measures. The focus is on linking capital planning to customer growth, cost drivers, and ensuring investments align with forecast benefits.

Reference: Exhibit N-1: Application - Section 9.0 (General Plant) (PDF Page 57)
Reference: Exhibit N-1: Application - Section 9.0 (General Plant) (PDF Page 57) a) General Plant capital for 2026 is forecast at $92.5 M, a significant increase from the 2025 budget of $65M. Please justify this elevated spending relative t...

AI summary The document requests justification for a significant increase in General Plant capital spending in 2026 compared to the 2025 budget, distinguishing between mandatory and discretionary projects. It also asks NS Power to explain the $22M vehicle replacement budget, evaluate deferral or extended asset life scenarios, and justify the prudence of this investment relative to historical averages.

Request IR-5: Topic: Cyber Attack a) Please confirm that no portion of the costs associated with the recent cyber security incident is being passed to ratepayers through this application.
Request IR-5: Topic: Cyber Attack a) Please confirm that no portion of the costs associated with the recent cyber security incident is being passed to ratepayers through this application. b) Explain the accounting "ring-fencing" measures i...

AI summary The document includes requests related to cybersecurity costs, ring-fencing measures, and grid services, specifically synchronous condensers. It also asks for a table detailing hydro system investments, production capacity, and production volume over the past ten years.

100705CA (NSPI) IR 1 to 32 - PDF 1 passage
34 Request IR-15:
34 Request IR-15: 35 36 With respect to Appendix I, CIs for transmission replacement and upgrade projects C0080110 and 37 C0080109, and 2024 ACE Plan Rebuttal Evidence (p. 22): 38 39 (a) Please confirm that NS Power's policy remains, "In t...

AI summary The proceeding requests Nova Scotia Power to confirm its policy on risk registers for transmission projects, explain the absence of risk registers for projects over budget, and justify the use of contingency budgets over ATO filings. It also asks about the impact of increased replacement structures on procurement and the Board's concerns regarding contingency amounts.

100706CA (NSPI) IR 1 to 32 - Word 4 passages
Section 8
1. Please confirm that NS Power’s policy remains, “In the case of Transmission Replacement and Upgrade projects, the project risks and their potential impacts are well understood by the project team, therefore having a risk register for ea...

AI summary The text consists of a series of questions directed at NS Power regarding its risk management practices, budgeting mechanisms, and project management for transmission replacement and upgrade projects. Specific focus is on risk registers, contingency budgets, and the impact of changes in project scope on procurement and scheduling.

Section 12
. Please explain why the cost of the switches identified in Attachments 1 and 2 is not excluded from the 20 percent contingency amount, similar to the approach taken for C0053214. 8. Please explain why the transmission structure replacemen...

AI summary The text contains a series of requests for explanations and justifications regarding various projects, including cost support, procurement processes, outage data, and future costs. These requests focus on transparency, accountability, and the reasoning behind specific decisions and expenditures.

Section 21
of risks that were overlooked, overstated, or successfully mitigated; and 3. Staff response to emerging problems, such as whether internal communication was effective and whether mid-course action mitigated those problems. 4. If, for any o...

AI summary The text requests a review of NS Power's post-project reviews, focusing on risk management, internal communication, and quality control. It also asks for actions taken since April 2024 to assess the acquisition of historical and forecast distribution cost data across various categories.

Section 22
ghts; and 4. External factors driving costs, including supply chain issues, shifts in the regular/overtime labour breakdown due to other utility programs. 2. In the referenced RIR, NS Power stated: NS Power has data on single-family and mu...

AI summary The text discusses NS Power's data tracking challenges, specifically regarding residential additions and internal work orders. It requests information on changes to work orders since 2025, updates on a continuous improvement initiative, and plans for future system upgrades.

101714Undertaking List 1 passage
Nova Scotia Power Inc. - 2026 Annual Capital Expenditure (ACE) Plan - $284 million p. p. 0
Nova Scotia Power Inc. - 2026 Annual Capital Expenditure (ACE) Plan - $284 million DATE: UND# DESCRIPTION REQUESTED OF BY DATE DUE April 21, 2026 U-1 To advise what the phrase, "Transactions per labour hour" refers to in the report on the...

AI summary The document outlines five requests for information related to Nova Scotia Power Inc.'s 2026 Annual Capital Expenditure (ACE) Plan, including queries about terminology, cost allocation, service availability, project updates, and directives from the Minister.

102208Closing Submissions - DOE 4 passages
Preamble p. p. 2
- These are the closing submissions of the Department of Energy, Government of Nova Scotia (the - "Department") regarding Nova Scotia Power Incorporated's ("NS Power", "NSP" or the "Utility") - 2026 Annual Capital Expenditure (ACE) Plan Ap...

AI summary The Department of Energy supports NS Power's 2026 ACE Plan but emphasizes the need for ratepayer affordability and cost-containment. Concerns are raised about the growing capital intensity and the need for comprehensive least-cost planning to ensure expenditures align with customer benefits and asset prudency.

Cyber Security Incident related costs p. p. 8
Cyber Security Incident related costs - The 2026 ACE Plan includes significant capital requests for enterprise systems, Customer - Information System (CIS) replacement and the IT-OT Cyber Security Control implementation. As - established d...

AI summary The 2025 ransomware incident exposed vulnerabilities in Nova Scotia Power's legacy systems, leading to billing inaccuracies and data compromises. The 2026 ACE Plan includes capital requests for system replacements, but the Department argues these costs should not be recovered from ratepayers, as they were already funded through existing rates, and should instead be covered by insurance or absorbed by shareholders.

Request to the Board p. p. 8
Request to the Board - The review of projects contained in Appendix A representing projects with escalation levels of - 50% or greater indicates significant increases across Generation, Transmission, Distribution, - Hydro, and General Plan...

AI summary The document requests the Board to conduct enhanced scrutiny of projects with significant cost escalations across various categories. It argues that these increases are not solely due to external factors but reflect broader issues like scope expansion and misclassification of expenses. The Department recommends procedural reviews to ensure proper governance and ratepayer protection.

Conclusion & Requested Board Actions p. pp. 8-15
Conclusion & Requested Board Actions - At a time when affordability pressures facing Nova Scotian households remain significant, the Board's oversight role becomes increasingly important. The Department therefore respectfully submits that...

AI summary The Department requests the Board to implement structural measures for the 2026 ACE Plan, including capping the ACE envelope, auditing the Fixed Asset Register, enforcing reliability performance accountability, and applying prudence reviews. These actions aim to ensure affordability, prudence, and alignment with public interest.

102213Closing Submissions - IG 8 passages
2. CEJC "Scope Change" Definition Must Allow for Meaningful Board Oversight Background p. p. 5
d. On the recommendation of the Industrial Group, the Board directed NSPI to engage with stakeholders to establish a new definition of Scope Change for the CEJC. Within its decision, the Board stated: …the Board agrees that more clearly de...

AI summary The NSEB is considering NSPI's proposal to redefine 'Scope Change' under the CEJC to focus on a project's stated goals and intent, rather than unexpected cost increases. The Board believes a clearer definition is needed to ensure meaningful oversight of capital projects.

The Proposed Definition Renders the Provision Meaningless p. p. 8
e rise to the application. While NSPI maintains in response to Undertaking U-5 that "any significant changes in the quantity of assets being invested in can be adequately captured within the ATO / FIN [ 29 ](#page-8-1) N-9, Evidence of Joh...

AI summary The text argues that the proposed definition of the ATO/FIN financial thresholds fails to provide adequate regulatory oversight for scope changes in capital projects. It highlights that Scope Change applications are meant to capture significant changes before they are embedded in costs, whereas the current approach only addresses overruns after the fact.

The Definition Should Be Consistent with NSPI's Established Practice p. p. 10
voir to its natural, pre-inundation levels, which was not a part of the approved project scope of work but in response to the water migration issues discovered after project approval.[36](#page-10-2) Once again, despite this confirmed scop...

AI summary The text discusses inconsistencies in how NSPI has handled scope changes in projects, such as the Tusket Main Dam Refurbishment, where significant changes occurred without proper applications. The Industrial Group argues that the proposed definition of 'scope' should align with established practices to avoid confusion and ensure consistency.

The Trend of Increased Spending p. pp. 11-12
The Trend of Increased Spending Against the CEJC definition of Routine Expenditures, the trend of significant increase in spending is problematic. As outlined in N-20, Routine Spending 2023-2026-IG, NSPI has increased its Program spending...

AI summary The document highlights a significant increase in Program spending by Nova Scotia Power Inc. (NSPI), rising by $90 million, or 70%, over the last four years. NSPI attributes this increase to factors such as right-of-way widening, new customer routines, utility-specific inflation, and the addition of new routines. This spending trend is being evaluated against the Capital Expenditure Justification Criteria (CEJC).

No Robust Routine Program-Level Review p. pp. 12-13
No Robust Routine Program-Level Review There is no distinct "routine review process" separate from NSPI's general capital scrutiny.[47](#page-13-0) NSPI relies on the same review process of any capital expenditure, and relies on the ACE pr...

AI summary The text discusses the lack of a distinct routine program-level review process for capital expenditures by NSPI, highlighting concerns about cost minimization, lack of monitoring for cost creep, and insufficient oversight of routine capital programs. It suggests that the Board should require NSPI to file detailed program-by-program reviews and establish a CEJC materiality trigger for routine capital growth.

The Sustained Increase p. p. 14
ided. Compounding the noted $200 million increase in the capital spending envelope is the fact that the Reliability Tie, and other capital expenses expected from the IESO-NS, are tracked separately. The Reliability Tie expenses have been r...

AI summary The document discusses the fragmentation of capital costs in the 2026 ACE Plan, noting that the Reliability Tie and other IESO-NS-related expenses are excluded from the plan. Despite this exclusion, these costs will still be recovered from ratepayers, raising concerns about the transparency and prudence of the capital program.

No Rate Impact or Affordability Analysis p. pp. 14-15
No Rate Impact or Affordability Analysis NSPI confirmed that when developing its capital program, "specific rate impacts are not calculated" at the program level.[57](#page-15-0) Instead, rate impacts related to the capital program are sai...

AI summary NSPI stated that rate impacts are not calculated at the program level but included in the GRA. Affordability considerations are addressed at the individual asset level and through the GRA process. However, there is no evidence of a rate impact assessment or affordability analysis for the Reliability Plan or its Year 2 implementation.

Recommended Direction p. pp. 17-18
Recommended Direction The Industrial Group submits that the Board should direct NSPI to include, in every subsequent submittal for IT or cybersecurity-related projects that were deferred or delayed as a result of the 2025 cyber incident: t...

AI summary The Industrial Group recommends that NSPI include detailed cost information in future submittals for IT or cybersecurity projects affected by the 2025 cyber incident. NSPI claims no restoration costs were captured in capital projects, but the Industrial Group argues that this information would help the Board ensure prudence and transparency in cost recovery.

102294Reply to Closing Submissions - NSPI 7 passages
2.2.1 Application Timing p. p. 6
2.2.1 Application Timing The IG states at page 10: More to the point, NSPI seeks approval to overspend only after the funds are committed and the size of the overrun is known. A Scope Change application is prospective so the Board has some...

AI summary The IG argues that NSPI's approach to filing ATO applications after overspending occurs lacks advance oversight. NS Power explains that timely filing is crucial to avoid financial consequences, such as costs being removed from rate base until regulatory approval is obtained, which limits cost recovery during delays.

2.5 Rate Impacts p. pp. 13-14
rates. Additionally, there should be consideration given to the overall impact of the annual capital expenditure plan on ratepayer classes, whether by an overall bill impact or affordability analysis. NS Power has not completed an analysis...

AI summary The document discusses the need to consider the impact of the annual capital expenditure plan on different ratepayer classes. NS Power has not completed a detailed analysis of revenue requirements, rates, or bill impacts by customer class for the ACE Plan due to uncertainties in assumptions such as load forecasts and financing.

3.7 CEJC Amendments The CA supports several of Mr. Wilson's proposed amendments to the CEJC, including clarifications around scope change, capital thresholds, and definitions of related projects, and recommends enhanced informational filings. NS Power submits that the existing CEJC framework, combined with ATO oversight and General Rate Application review, already provides a robust capital governance structure. The Company has indicated areas where it agrees with Mr. Wilson's recommendations, particularly regarding clarification of the scope change definition. NS Power has also addressed the notion of a two-step process in responding to the IG's Closing submissions at Section 2.2 above. Where NS Power has not agreed with additional procedural requirements, this is primarily because these measures reflect existing practices and would therefore add administrative burden without changing outcomes or enhancing oversight. p. pp. 22-23
3.7 CEJC Amendments The CA supports several of Mr. Wilson's proposed amendments to the CEJC, including clarifications around scope change, capital thresholds, and definitions of related projects, and recommends enhanced informational filin...

AI summary The CA supports certain amendments to the CEJC, including clarifications on scope change and capital thresholds. NS Power argues that the current CEJC framework, along with ATO oversight and General Rate Application review, is already sufficient for capital governance. The company agrees on some clarifications but opposes additional procedural requirements due to potential administrative burden.

Preamble p. p. 29
- The proposed audit is unwarranted and unsupported. NS Power's annual financial statements are - prepared in accordance with applicable accounting standards and are independently audited, and - the Company's Management's Discussion and An...

AI summary NS Power argues that an audit is unwarranted, stating that its financial statements are prepared according to accounting standards and are independently audited. It emphasizes compliance with Board-approved accounting policies and the existence of a continuous, auditable record of asset valuation and cost recovery.

5.5 Project Cost Escalation p. pp. 30-31
5.5 Project Cost Escalation DOE submits: The evidence demonstrates that material project escalation is not limited to isolated projects or unique operational circumstances but instead reflects a broader and recurring pattern across the uti...

AI summary DOE argues that project cost escalation across multiple categories indicates a recurring pattern, not just isolated issues. They note that the ACE Plan is a planning process, not a fixed-price commitment, and emphasize that budget changes over time do not necessarily imply imprudence. The regulatory framework, including ATOs, provides accountability for significant variances.

5.7 DOE's Requests of the Board Imposing caps or ceilings on capital expenditures would fundamentally conflict with NS Power's statutory obligation to provide safe and adequate service. Such limits would represent a departure from evidence-based and risk-driven asset management, potentially exposing NS Power's customers to unacceptable reliability and safety risks. Defined expenditure limits bear no relationship to the physical condition of assets or the pace of deterioration. Instead, they would force the Company to make arbitrary decisions about which risks to accept and which customers to leave vulnerable. The appropriate safeguard is not a cap or ceiling, but rather evidence-based scrutiny at the project- level, which is precisely what the ACE Plan process is designed to provide. This framework allows the NSEB to rigorously assess whether each proposed investment is necessary for safe and adequate service and whether the associated costs are just and reasonable. p. pp. 33-34
5.7 DOE's Requests of the Board Imposing caps or ceilings on capital expenditures would fundamentally conflict with NS Power's statutory obligation to provide safe and adequate service. Such limits would represent a departure from evidence...

AI summary The Department of Energy argues that imposing caps on capital expenditures would conflict with NS Power's obligation to provide safe and adequate service, as such limits would not align with evidence-based asset management and could expose customers to reliability and safety risks. Instead, the ACE Plan process is presented as the appropriate safeguard for project-level scrutiny.

6.0 CONCLUSION In this proceeding, NS Power has demonstrated that the investments proposed in the 2026 ACE Plan are prudent, necessary, and aligned with the Company's statutory obligation to provide safe and adequate service to customers. The evidentiary record shows that these investments have been appropriately developed, assessed pursuant to the CEJC, and are responsive to the evolving operating conditions facing the system, including aging infrastructure, increasing electrification, and legislated policy requirements. The concerns raised by intervenors do not identify any material gaps in the existing regulatory framework or evidentiary record that would justify the imposition of additional reporting requirements or structural constraints. Further, introducing caps, duplicative reporting, or additional approval layers would not enhance oversight, but would instead risk delaying necessary investments and increase costs and operational risks. In terms of affordability and consciousness of the cost impact to customers, this is a serious issue for customers and one that NS Power is focused on addressing through solutions that maintain a safe and reliable energy supply for Nova Scotians while keeping rates low. At the project level, NS Power is required to pursue the least cost means of addressing identified risks. At the system level, overall capital spending and its impact on rates are assessed through the GRA process. Together, these processes ensure that customer impacts are considered alongside the need to maintain safe, reliable, and resilient service. For these reasons, NS Power respectfully submits that the Board should approve the 2026 ACE Plan capital projects and routines as filed, the revised Summary CEJC as amended in NS Power's Rebuttal Evidence, and decline the additional directives proposed by intervenors. p. pp. 34-35
6.0 CONCLUSION In this proceeding, NS Power has demonstrated that the investments proposed in the 2026 ACE Plan are prudent, necessary, and aligned with the Company's statutory obligation to provide safe and adequate service to customers....

AI summary NS Power argues that the 2026 ACE Plan investments are prudent and necessary, aligning with statutory obligations. They claim the investments are appropriately developed and assessed, with no material gaps in the regulatory framework. NS Power emphasizes affordability and the need to maintain safe, reliable service while keeping rates low. They recommend the Board approve the plan and reject additional directives.

103410Decision 10 passages
2.2.2 C0021608 – TUC Shoreline Sheet Pile Refurbishment p. p. 7
may have changed the scoring spread. The Board also expressed similar spread concerns related to scoring the options' costs, as it was not based on pro-rating an option cost to the lowest option cost. • The use of additional study data to...

AI summary The Nova Scotia Energy Board (NSEB) raised concerns about the cost estimates for the rock revetment option in the TUC Shoreline Sheet Pile Refurbishment project. NS Power completed additional studies that significantly increased the rock revetment option's cost, but the Board noted that the other options were not re-evaluated based on the new data, potentially affecting the cost-effectiveness of the chosen solution.

2.3.1.1 Findings p. pp. 18-20
2.3.1.1 Findings [44] The Board accepts that an increase in expenditure does not, in itself, mean that an activity ceases to qualify as routine. Required expenditures may reasonably vary with asset conditions, customer growth, system requi...

AI summary The Board acknowledges that increases in routine expenditures do not automatically disqualify activities as routine but is concerned that temporary cost increases may become embedded in historical data, influencing future forecasts. NS Power is urged to distinguish between structural and temporary cost drivers in future ACE Plans.

2.3.2 Enhanced Tracking and Cost Minimization p. pp. 20-21
2.3.2 Enhanced Tracking and Cost Minimization [49] The CA raised concerns regarding NS Power's ability to demonstrate cost minimization within the Distribution Routines. In his evidence, Mr. Wilson observed that regular and overtime person...

AI summary The CA raised concerns about NS Power's ability to demonstrate cost minimization in Distribution Routines, noting that overtime hours were not routinely tracked. NS Power clarified that while their accounting software tracks labour hours and costs, this information is not always used for forecasting, as highlighted in the exchange between Mr. Murphy and Mr. Beaton.

2.3.4.1 Findings p. pp. 26-27
2.3.4.1 Findings [64] The Board accepts that the formal Basis of Schedule process should not be imposed on all routine activities. However, the Board agrees with the underlying objective of the CA's recommendation. For planned routines inv...

AI summary The Board acknowledges that the formal Basis of Schedule process should not apply to all routine activities but supports the objective of ensuring proper planning and minimizing avoidable costs for significant routines. It suggests that NS Power's existing Work Management and Scheduling systems can achieve this goal effectively.

2.3.5.1 Findings p. pp. 27-28
2.3.5.1 Findings [69] The Board does not consider that the demonstrated accuracy of the forecasting methodology resolves the information issue raised by the CA. Forecast accuracy and forecast justification are distinct considerations. A fo...

AI summary The Board emphasizes that forecast accuracy alone does not resolve information issues raised by the Commissioner of the Inquiry. It stresses the importance of activity data, such as changes in customer mix and load increases, to assess expenditure forecasts. The Board also expects NS Power to provide supporting information when attributing cost increases to external factors like supply-chain constraints.

2.4.2 Directives p. p. 33
2.4.2 Directives [88] The Board finds that the sustained growth and evolving composition of the Routine Program require requires enhanced prospective transparency. The additional information is intended to preserve the regulatory efficienc...

AI summary The Board requires NS Power to enhance transparency and reporting for the Routine Program, including detailed financial and operational data, to ensure regulatory efficiency and proper cost justification. This includes rolling five-year comparisons, cost breakdowns, and explanations for changes in expenditures.

3.2 CEJC Scope Change Amendments and Recommendations p. pp. 36-37
3.2 CEJC Scope Change Amendments and Recommendations [99] Capital project Scope Change applications are currently addressed in Section 12.2 of NS Power's Capital Expenditure Justification Criteria. These are intended to address changes in...

AI summary The document discusses the need to define 'Scope Change' in the CEJC, as raised by the IG during the 2025 ACE Plan proceeding. The Board agreed and directed NS Power to consult on incorporating a definition into the CEJC for the 2026 ACE Plan.

3.2.1 Findings p. p. 42
project costs and/or operational risks would not arise with a delay in work. In these cases, a Scope Change application would be prospective, providing the Board with regulatory oversight in advance. [113] NS Power also stated that it ende...

AI summary The document discusses the regulatory framework for ATO applications and Scope Change applications, emphasizing the importance of timely filing to ensure cost recovery and regulatory oversight. NS Power argues that early filing of ATO applications reduces the need for Scope Change applications, but the Board suggests there may still be situations where Scope Change applications are necessary even before ATO thresholds are exceeded.

5.0 CAPITAL SPENDING GROWTH p. p. 60
l of accuracy as those contained in an approval application. That is one of the reasons they are not included for approval in the ACE Plan. Every project presented to the Board is scrutinized based on the same basic criteria: is the projec...

AI summary The document discusses the Board's approach to reviewing capital projects in the ACE Plan, emphasizing the need for detailed project reviews rather than structural capping. It highlights concerns that capping could lead to deferred expenditures and higher rate increases, and mentions the importance of aligning with public utility principles.

11.0 CONCLUSION p. p. 96
ant cost categories. For Routines using internal labour the information should also include a breakdown of labour costs (regular and overtime labour, budgeted costs and hours, actual costs and hours). - 3. NS Power must provide sufficient...

AI summary The document outlines requirements for NS Power to provide detailed cost breakdowns and explanations for changes in routine expenditures, including labor, materials, and contractor costs, and to assess the use of existing systems for monitoring productivity and cost trends. It also mandates the inclusion of Routine Expenditure provisions in the stakeholder review for the 2028 ACE Plan.

103411Board Order 1 passage
ORDER
ant cost categories. For Routines using internal labour the information should also include a breakdown of labour costs (regular and overtime labour, budgeted costs and hours, actual costs and hours). - 3. NS Power must provide sufficient...

AI summary The document outlines requirements for NS Power to provide detailed cost breakdowns and explanations for changes in routine expenditures, including labour, materials, and contractor costs. It also mandates monitoring of planned and reactive replacement activities and the inclusion of Routine Expenditure provisions in the 2028 ACE Plan.

20260421-1Hearing Transcript — 04/21/2026 (Revised Transcript - Refiled May 20, 2026) 3 passages
OPENING STATEMENT 27 NS DEPT. OF ENERGY
OPENING STATEMENT 27 NS DEPT. OF ENERGY 1 the burden of those overruns falls onto ratepayers. 2 For example, some of the hydro plants 3 produce minimal energy and yet work on them has often 4 proceeded in the face of significant cost overr...

AI summary The Department of Energy highlights concerns over cost overruns in hydro plant projects and calls for regulatory scrutiny of the 2026 ACE Plan, emphasizing the need for accountability and alignment with the IESO mandate. It also requests the Board to disallow ratepayer funding for certain projects, arguing that financial consequences should be borne by shareholders, not ratepayers.

NS POWER PANEL 89 Cr-ex, (Murphy)
NS POWER PANEL 89 Cr-ex, (Murphy) 1 that would benefit the future load forecasting. 9 tagged with certain customer type. So where the costs 10 would end up would be the exact same as they are today, 11 whether we had that information or no...

AI summary The discussion centers on cost allocation between rate classes and the potential for improved rate design, with a focus on whether data would be useful for these purposes. The chair outlines an undertaking to review and provide information on these topics.

Section 161
recorded as capital costs? - A. (Beaton) No, they weren't. Part of the work we did last year was to ensure that no costs related to the restoration due to the cyber event were captured in any capital project. So those all would have been b...

AI summary The discussion confirms that cybersecurity-related restoration costs were not included in capital projects and were instead handled separately by the utility or through insurance. A monthly review process ensures that such costs are excluded from the rate base, with quarterly adjustments made accordingly.

20260422-1Hearing Transcript — 04/22/2026 (Revised Transcript - Refiled May 20, 2026) 8 passages
NS POWER PANEL 521 Questions, (Chair)
NS POWER PANEL 521 Questions, (Chair) 1 that are reflected in this routine. It's also there is 13 Could we just hold on for one Q. 14 second? 15 (SHORT PAUSE) 16 Never mind. My apologies. THE CHAIR: 17 BY THE CHAIR: 18 Okay. I'm going to t...

AI summary The Chair of the NS Power Panel 521 is discussing the reasonableness of costs associated with transmission line replacement and upgrade projects approved since the 2021 ACE Plan. The Chair notes that while cost data is available, there is a need for a benchmark to assess whether these costs are reasonable.

NS POWER PANEL 529 Questions, (Chair)
NS POWER PANEL 529 Questions, (Chair) 1 Q. And I was just wondering if those 14 Q. Okay. My next question relates 15 to it's basically the project Exhibit N-6, PDF page 16 605, and it's Board IR-146. But it relates to the 17 intelligent as...

AI summary The Chair of NS Power Panel 529 asks about the cost structure of the intelligent asset data capture and integration platform project, including the role of third-party funding and the inclusion of end user licenses in the total project cost estimate of $10.3 million.

NS POWER PANEL 541 Questions, (Chair)
NS POWER PANEL 541 Questions, (Chair) 1 put the page number on this one. So it's IR-182, Board 2 IR-182. Okay. And it's (a). 3 BY THE CHAIR: 4 And the question was: Q. 5 6 7 8 9 Given that the Plan is projected to cost approximately $1.3 [...

AI summary The Chair of the NS Power Panel 541 questions whether NS Power has calculated the impact on rates from the Five-Year Reliability Plan, which is projected to cost approximately $1.3 billion over five years. The answer indicates that the investment is included in the General Rate Application (GRA) before the NSEB in matter M12451 and that the plan follows a least-cost approach to meet performance standards by 2029.

Cr-ex, (Kayter)
Cr-ex, (Kayter) 1 up the right discussion points. 2 Thank you. Q. 3 For my next question, I refer you to 4 PDF page 21 to 22 of Exhibit N-9, CEJC Updates, Scope 5 Change Definition. 6 Question: Your proposal for more 7 rigorous scope chang...

AI summary The discussion centers on the need for a rigorous scope change definition to prevent cost overruns in utility projects. The witness references past projects like Tusket Falls and Marshall Falls, which experienced significant cost overruns, and mentions IR-16 from the Board's IR set as relevant context.

Section 158
INTERNATIONAL REPORTING INC. CERTIFIED COURT REPORTERS think on an earlier question I pointed out that that was a Nova Scotia Power staff during I think the usefulness of that information is in identifying whether Nova Scotia Power's work...

AI summary The discussion focuses on the efficiency of Nova Scotia Power's distribution routines and cost minimization strategies. The speaker acknowledges that the PDM model does not apply well to distribution and transmission routines, necessitating alternative methods to track and verify cost optimization. The speaker also notes a change in opinion based on evidence presented by the Industrial Group.

Section 161
INTERNATIONAL REPORTING INC. CERTIFIED COURT REPORTERS in some cases, I left some points, you know, sort of to the Board's discretion and others that I made more concretely. BY MR. KAYTER: Q. Thank you, Mr. Wilson. Two questions anticipate...

AI summary The discussion centers on acceptable levels of project cost escalations, referencing the Board's non-binding contingency guidelines and a recommendation for a 10 percent contingency cap on transmission projects without risk matrices. Nova Scotia Power is noted as following these guidelines generally.

Section 162
he non- binding contingency guidelines have been worked out effectively and Nova Scotia Power's generally following those. So that's one mechanism for determining what level WILSON Cr-ex, (Kayter) INTERNATIONAL REPORTING INC. CERTIFIED COU...

AI summary The discussion outlines mechanisms for determining reasonable cost escalation for approved capital projects, including adherence to contingency guidelines, potential ATO proceedings for cost overruns, and consideration during general rate cases if cost overruns affect the rate base.

Section 164
6 Five-Year Reliability Plan to develop additional 17 recommendations. 18 And I think there's a number of 19 capital projects that are underway that I think will lead WILSON Cr-ex, (Kayter) INTERNATIONAL REPORTING INC. CERTIFIED COURT REPO...

AI summary The discussion centers on cost minimization opportunities in IT and grid-enhancing technologies, including the Work Asset Management Program and projects identified through the IRP. These initiatives are seen as important for reducing transmission expansion costs and system congestion.

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